Before finding that legal fees incurred to quash a conviction so as to ultimately result in reinstatement satisfied s. 8(1)(b), Bowie J stated (at para. 10):
[T]here was more than one bona fide, actual real and true objective in the taxpayer's mind.
Before finding that legal fees incurred to quash a conviction so as to ultimately result in reinstatement satisfied s. 8(1)(b), Bowie J stated (at para. 10):
[T]here was more than one bona fide, actual real and true objective in the taxpayer's mind.